This Safety and Health Information Bulletin is not a standard or regulation, and it creates no new legal obligations. The Bulletin is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace. Pursuant to the Occupational Safety and Health Act, employers must comply with hazard-specific safety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, pursuant to Section 5(a)(1), the General Duty Clause of the Act, employers must provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm.
Approximately 28 million Americans have some degree of hearing loss [1,9]. Hearing loss can result from a variety of factors, including: heredity, disease, physical trauma, and exposure to loud noises. The National Institute for Occupational Safety and Health (NIOSH) estimates that 10 million American workers have permanent hearing loss resulting from exposure to excessive noise at work . The number of American workers with hearing loss from all sources is expected to increase over time as the workforce ages.
Hearing-impaired workers face challenges responding to emergencies, working safely around machinery, communicating with coworkers, and receiving training. Accommodations necessary to address these challenges may not be part of an employer's current hearing conservation practice. This Safety and Health Information Bulletin (SHIB) focuses on (1) Emergency/Evacuation Response Considerations for Hearing-Impaired Workers; and (2) Workplace Safety and Health Considerations for Hearing- Impaired Workers.
The purpose of this SHIB is to provide employers, workers and professional organizations guidance on accommodating the safety and health needs of hearing-impaired individuals in the workplace. Specifically, this SHIB:
The Occupational Safety and Health Administration's (OSHA) Occupational noise exposure standard includes requirements for a hearing conservation program (29 CFR 1910.95(c)). It covers employers in general industry with employees exposed to noise at 85 decibels (dBA) or above measured as an 8-hour time-weighted average sound level (TWA). It requires these employers to include their noise-exposed employees in a hearing conservation program that consists of noise exposure assessment, audiometric testing, hearing protection and training.1 The nature of the workplace has changed since the standard took effect; many workers in the United States are aging and have some degree of hearing loss. There is also greater concern among workers about readiness to safely react to catastrophic events. In addition to emergencies caused by natural disasters, and technological accidents; possibility of acts of terrorism have become a concern. Accommodations are available to enable hearing-impaired workers to evacuate safely, and certain accommodations may benefit workers with no hearing loss, since some emergencies may adversely impact all workers' ability to hear or communicate. Accommodation measures in the workplace are an extension of good communication and safe practices for all workers.
Hearing-impaired workers also face routine workplace safety and health challenges. In particular, hearing-impaired workers may have difficulty understanding audible warning signals and alarms designed to indicate the approach of motorized vehicles. For those with severe and profound hearing losses, a common safety concern is localization. For example, "I know there are forklifts in the area but I do not know where they are coming from." Other concerns expressed by hearing-impaired workers include difficulty understanding conversation on the telephone, at meetings and in training sessions . Fortunately, accommodations and equipment modifications are available to assist hearing-impaired workers to perform their jobs safely [4,9].
Customizing Worksite Emergency Preparedness for Hearing-Impaired Workers
The OSHA Emergency action plans standard (29 CFR 1910.38) requires an employer to develop a written emergency action plan when such a plan is required by a specific OSHA standard, such as 29 CFR 1910.120 hazardous waste operations and emergency response, and 29 CFR 1910.160 fire extinguishing systems. When the plan is required, it must describe the actions employees should take to ensure their safety if a fire or other emergency situation occurs. At a minimum, the plan must include: emergency escape procedures; procedures for employees who remain to operate critical plant operations before they evacuate; procedures to account for all employees after emergency evacuation; and procedures for reporting fires and other emergencies. The plan must also include the types of evacuation to be used in emergency circumstances. The employer must review the plan with each employee covered by the plan when it is developed, whenever the plan changes and upon an employee's initial assignment. Employers must consider employees with disabilities in the development of an emergency action plan when such a plan is required by a specific OSHA standard.
The plan must be in writing, kept in the workplace, and available to employees for review. For employers with 10 or fewer employees, the plan may be communicated orally and the employer does not have to maintain a written plan. The Appendix to 1910, Subpart E, Exit Routes, Emergency Action Plans, and Fire Prevention Plans is a nonmandatory guideline to assist employers in complying with the requirements of the employee emergency plan .
The Americans with Disabilities Act (ADA) does not require employers to have an emergency evacuation plan, but if an employer decides to have such a plan, they are required to include people with disabilities [10,14].
To help prepare workers for emergencies, the Office of Disability Employment Policy (ODEP), at the U.S. Department of Labor, provides recommendations on emergency preparedness for people with disabilities. The ODEP report suggests three essential parts to an emergency evacuation plan: plan development, plan implementation and plan maintenance .
Plan development includes identifying the potential hazards, the accommodation needs of persons with disabilities, and key personnel who will be involved in an emergency. In developing a plan, employers should ask their employees for their input, and workers with disabilities should take responsibility for their safety by offering their ideas and input. The plan should address after-hours situations, and include a method to identify visitors with special needs. The plan also should include details on how information will be conveyed to hearing-impaired workers when they are away from their work areas. Finally, the plan should be easy to read and understandable.
Employers should consult with local fire, police and emergency departments as well as community-based organizations in developing the plan. While the plan should be in writing, it should be viewed as an ongoing process, periodically revised and updated to reflect changes in technology, personnel and procedures.
Plan implementation involves distribution of the plan in an accessible format to all employees and the integration of the plan into the employer's standard operating procedures. Drills, both scheduled and unscheduled, should be performed regularly. Such practice drills should encompass the needs of all individuals, including workers with disabilities, to ensure familiarity with the procedures and to determine where improvements are needed.
Plan Maintenance involves developing a system for identifying new safety concerns and the needs of new disabled employees, reviewing and modifying plans after practice drills, and ensuring that emergency equipment is being properly maintained in good operating condition [4,5,9,10].
Alerting Device Options
Traditionally, notification of an emergency has been done through the use of auditory devices which are effective for most workers. OSHA's Employee Alarm Systems standard (29 CFR 1910.165), addresses all emergency alarms required to be installed by specific OSHA standards. The standard indicates that an alarm system must provide warning for necessary emergency actions and be capable of being perceived above ambient noise by all employees. Since hearing-impaired employees may not be able to hear auditory alarms, OSHA considers strobe lights or similar lighting devices and tactile devices to meet the requirement of the standard .
Hearing-impaired workers may also have difficulty understanding voice communication over the public address (PA) system. The alarm may interfere with or drown out voice announcements, making the emergency voice communication system ineffective. Alerting device accommodations are available to notify hearing-impaired workers of emergencies, and they cause minimal distraction to other workers. Visual alarms equipped with flashing strobe lights or vibrating alerting devices can be hard-wired into the existing emergency notification system. The Underwriters Laboratories Standard for Emergency Signaling Devices for the Hearing-Impaired (UL 1971), establishes criteria for systems used for emergency notification .
Section 4.28 of the ADA Accessibility Guidelines (ADAAG)2 specifically addresses specialized alarms (www.access-board.gov/adaag/html/adaag/htm#4.28). To be effective for notification, visual alarms must be installed where hearing-impaired persons can see them .
Many alerting device options are available for use in the workplace, depending on the particular needs of the hearing-impaired worker. However, not all of the devices listed below are appropriate for every hearing-impaired worker. Some of the devices are more appropriate for individuals with a severe-to-profound hearing loss, while others are appropriate for workers with a mild hearing impairment. The employer should work together with hearing-impaired employees, and perhaps with an occupational audiologist, in determining the device or combination of devices that work best for their particular situation.
Some alerting device options include:
The Job Accommodation Network (JAN) website, a service of the Office of Disability Employment Policy, has a wealth of information on alerting devices at www.jan.wvu.edu. JAN's "Employers' Guide to Including Employees with Disabilities in Emergency Evacuation Plans" covers requirements for including people with disabilities, guidelines and accommodation considerations. Toll-free (800) 526-7234 .
Other useful resources are Disability Info, www.disabilityinfo.gov and the Center for Disability Issues and Health Professionals.
The United States Fire Administration publishes many guides on the subject of disability and related emergencies, toll-free (800) 561-3356 [5,6,8].
Other Safety and Health Workplace Accommodations
The ADA Standards for Accessible Design, as well as other technical assistance materials, can be obtained from the U.S. Department of Justice ADA website. The Department of Justice operates a toll-free ADA Information Line at (800) 514-0301 (voice), or TTY (800) 514-0383, which directs callers to an ADA specialist [5,6,10,12,14].
Responding to Vehicles in the Workplace
Workers with hearing loss working around or operating powered industrial trucks (e.g., forklifts) or other heavy equipment may be concerned about their ability to detect dangerous situations. The employer should work together with hearing-impaired employees in determining the accommodation or combination of accommodations that work best for their particular situation. The following are suggested accommodations that can be made to minimize such safety risks:
Training is an integral component of a safe workplace, yet training may pose unique challenges for employers who have workers with hearing impairments. Training programs that ensure that procedures are understood and followed are paramount to creating a safe work environment .
Hearing-impaired workers often need customized training tools to ensure their safety. There are a variety of training mechanisms that can be tailored to hearing-impaired individuals in the workplace. Again, the decision to use a particular training accommodation is one that should be made by the employer and employee after considering the needs of a specific situation.
Tips for Assisting People with Hearing Impairments
The risk of miscommunication, injury, and other dangers presented to hearing-impaired workers in the workplace can be minimized through the implementation of the practical steps described above. The best way to help hearing-impaired employees feel prepared for a workplace emergency and be motivated to use safe work practices is to solicit their input and provide knowledge, information, and accommodation choices.
ODEP - Job Accommodation Network (JAN) www.jan.wvu.edu
Independent Federal Agency
National Institute on Disability and Rehabilitation Research (NIDRR)
1OSHA's standard at 29 CFR 1926.52 addresses occupational noise exposure in the construction industry.
2ADAAG contains scoping and technical requirements for accessibility to buildings and facilities by individuals with disabilities under the ADA. These scoping and technical requirements are to be applied during the design, construction, and alteration of buildings and facilities covered by Titles II and III of the ADA to the extent required by regulations issued by Federal agencies, including the Department of Justice and the Department of Transportation, under the ADA.
*Accessibility Assistance: Contact OSHA's Directorate of Technical Support and Emergency Management at (202) 693-2300 for assistance accessing PDF materials.
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